When the reg talks about issuing a revised TIL if the APR is out of tolerance does this mean issuing a revised [2nd] Early TIL then the final TIL will be provided at closing, or would the final TIL that we normally give at closing even be required if we gave the revised [2nd] Early TIL? We give a Final TIL at closing, but was curious if it was required if nothing changed after the revised TIL was given. Could someone clarify for me. Thanks.

Final TIL's are not actually required. But without them, how would you evidence that you are within tolerances?

When something changes that puts us out of tolerance, we issue a revised TIL (obviously to prevent holding up settlement), but we still issue a final TIL.

Thanks for clarifying and confirming.